In This Issue

Texas Railroad Commission Proposed Safety Regulation Updates

Effective December 18, 2007, the Texas Railroad Commission (TRRC) withdrew the proposed amendments and revisions to 16 TAC Chapter 8 – Pipeline Safety Regulations to address new risk management initiatives for the Commission’s pipeline safety evaluation program and to remove outdated or duplicative rule requirements. The proposed amendments included new language to address onshore pipelines and gathering and production facilities. Please reference RCP’s newsletter article on the proposed revisions in the November 2007 edition of DOT Pipeline Compliance News. These proposed revisions to Chapter 8 Pipeline Safety Regulations appeared in the October 26, 2007 issue of the Texas Register (32 TexReg 7575), and comments on the proposed revisions were due on November 26. Click here to view TRRC’s filing to withdraw.

In addition, the TRRC has proposed new regulations for risk-based schedules for leak surveys (16 TAC 8.206), leak grading and repair using modified Gas Piping Technology Committee (GPTC) standards (16 TAC 8.207), and mandatory removal and replacement program for compression couplings on gas distribution pipelines (16 TAC 8.208). These new regulations are intended to be applied primarily towards gas distribution operations. Comments are due to the TRRC by February 5, 2008.

At a meeting on Tuesday, January 8th, the TRRC discussed comments regarding these new rules as well as the withdrawn regulations. Expect the withdrawn regulations to be proposed again with several changes sometime in February. A few items of interest from these discussions are as follows:

  • Removal of gathering pipelines from the Texas Integrity Management regulations (16 TAC 8.101) is expected to remain as originally proposed when the new proposals are issued in February. In the mean time, operators who wish to request waivers from Texas Integrity Management regulation requirements may do so by submitting a written request to the TRRC.
  • Timelines for compliance are expected to be included in the new proposed rulemakings in February.
  • The TRRC intends to reissue regulations that apply to pipelines that may have been recently exempted by the new gas gathering definition. Consideration is being given to create a new classification of regulated lines such as “regulated production lines” or something similar to that affect. The intent would be to apply safety regulations to these pipelines located in populated areas that may or may not have been regulated prior to the new federal definition for gas gathering pipelines.
  • The TRRC clarified that the proposed T4 permit requirements were not intended to be applied towards pipelines such as gas distribution that have been exempt from these requirements in the past.
  • Discussions were held regarding the responsibility for odorization of gas pipelines that serve large industrial consumers who might also be using the gas for domestic purposes as well. The TRRC will accept further comments from operators on how best to verify that large volume consumers utilize odorized for domestic purposes.
  • Discussions were held regarding proposed risk-based schedules for leak surveys (16 TAC 8.206), leak grading and repair using modified Gas Piping Technology Committee (GPTC) standards (16 TAC 8.207), and mandatory removal and replacement program for compression couplings on gas distribution pipelines (16 TAC 8.208). Comments received from operators indicate a desire to remain consistent with current national standards.